instructor guide globally harmonized system for hazard ...globally harmonized system for hazard...

35
Instructor Guide Globally Harmonized System for Hazard Communication (GHS) Awareness Level Training MU221-15 Carrol L. Herring Fire and Emergency Training Institute Louisiana State University 6868 Nicholson Drive Baton Rouge, LA 70802 October 22, 2013 Ken Fowler, FETI Instructor

Upload: others

Post on 21-Jan-2020

17 views

Category:

Documents


0 download

TRANSCRIPT

Page 1: Instructor Guide Globally Harmonized System for Hazard ...Globally Harmonized System For Hazard Communication MU221-15 GHS Awareness Level Training 10/22/13 MU221-15 GHS Awareness

Instructor Guide

Globally Harmonized System for

Hazard Communication (GHS)

Awareness Level Training

MU221-15

Carrol L. Herring

Fire and Emergency Training Institute

Louisiana State University

6868 Nicholson Drive

Baton Rouge, LA 70802

October 22, 2013

Ken Fowler, FETI Instructor

Page 2: Instructor Guide Globally Harmonized System for Hazard ...Globally Harmonized System For Hazard Communication MU221-15 GHS Awareness Level Training 10/22/13 MU221-15 GHS Awareness

Globally Harmonized System For Hazard Communication

MU221-15 GHS Awareness Level Training

10/22/13 MU221-15 GHS Awareness Page 2 www.feti.lsu.edu

Blank Page

Page 3: Instructor Guide Globally Harmonized System for Hazard ...Globally Harmonized System For Hazard Communication MU221-15 GHS Awareness Level Training 10/22/13 MU221-15 GHS Awareness

Globally Harmonized System For Hazard Communication

MU221-15 GHS Awareness Level Training

10/22/13 MU221-15 GHS Awareness Page 3 www.feti.lsu.edu

GHS Awareness Level Training for Emergency Responders

Instructor Guide

Topic: Understanding the OSHA HazCom Plan Changes

Level of Instruction: Online or Direct Delivery

Time Required: 3 hours

This course intended as a hand-off for instruction by local fire department officers to their

agency.

Materials:

Appropriate audiovisual devices

Internet Connectivity

Instructor Lesson Plan

PowerPoint Program

Student Activity Sheets

ERG 2012

References:

Occupational Safety & Health Administration Hazardous Communication Standard CFR

1910.1200 (2012)

NFPA 704 Standard System for Identification of the Hazards of Materials for Emergency

Response, 2012 Edition. Tables 5.2, 6.2, 7.2 and Chapter 8 of NFPA 704

Emergency Response Guidebook 2012, Washington, DC: U.S. Department of

Transportation, Pipeline and Hazardous Materials Safety Administration.

DOT Chart 15: Hazardous Materials Marking, Labeling and Placarding Guide. United

States. (2007). Washington, DC: U.S. Dept. of Transportation, Pipeline and Hazardous

Materials Safety Administration.

Page 4: Instructor Guide Globally Harmonized System for Hazard ...Globally Harmonized System For Hazard Communication MU221-15 GHS Awareness Level Training 10/22/13 MU221-15 GHS Awareness

Globally Harmonized System For Hazard Communication

MU221-15 GHS Awareness Level Training

10/22/13 MU221-15 GHS Awareness Page 4 www.feti.lsu.edu

GHS AWARENESS LEVEL TRAINING

CURRICULUM OUTLINE

Note: Personnel attending should be should have a current understanding of the Emergency

Response Guidebook including its format and use, placards, and NFPA 704 markings, but it is

not a formal prerequisite.

SUBJECT RECOMMENDED

Time

Globally Harmonized System – Hazard Communication 2012 2

Emergency Response Guidebook 2012 1

Activity Worksheet ERG 2012 .5

Activity Worksheet SDS .5

Activity Worksheet NFPA (Optional) Minimal

TOTAL RECOMMENDED HOURS 3

Page 5: Instructor Guide Globally Harmonized System for Hazard ...Globally Harmonized System For Hazard Communication MU221-15 GHS Awareness Level Training 10/22/13 MU221-15 GHS Awareness

Globally Harmonized System For Hazard Communication

MU221-15 GHS Awareness Level Training

10/22/13 MU221-15 GHS Awareness Page 5 www.feti.lsu.edu

PREPARATION:

Motivation:

Recent changes in OSHA's Hazard Communication Standard brought the regulation in

line with international standards through the creation of the Global Harmonizing System

(GHS). Implementing the Global Harmonizing System, helps ensure quality and

consistency in the classification and labeling of all chemicals; improving emergency

responders ability to quickly understand critical safety information.

Student Performance Objective:

Upon completion, the student will be able to identify major changes in the Safety Data

Sheet (formally Material Safety Data Sheet) format, identify Safety and Health Labeling

requirements. Describe the new GHS Pictograms and Signal Words that identify the

hazards associated with a given chemical, understand the basics of the new system for

Hazard Classification. Be able to recognize employer requirements to prepare for and

implement the new requirements according to the allotted timeframe. Understand the

conflict between GHS and NFPA 704.

Overview:

The Globally Harmonized System (GHS): This awareness level course is introductory in

nature and is designed to inform the student of recent changes to OSHA’s Hazard

Communication Standard and the movement to establish a Globally Harmonized Hazard

Communication System. Major changes to the Hazard Communication Standard covered

by this course include Hazard Classification, Labels and Safety Data Sheets (SDS), as

well as benefits of changes, impacts on transportation, documentation, and information

for the emergency responder.

Page 6: Instructor Guide Globally Harmonized System for Hazard ...Globally Harmonized System For Hazard Communication MU221-15 GHS Awareness Level Training 10/22/13 MU221-15 GHS Awareness

Globally Harmonized System For Hazard Communication

MU221-15 GHS Awareness Level Training

10/22/13 MU221-15 GHS Awareness Page 6 www.feti.lsu.edu

This training course has been developed directly from the GHS requirements as

outlined in the updated OSHA Hazard Communication Standard and is intended to

help emergency responders meet the basic training requirements for GHS of the new

Standard.

Understanding the OSHA HazCom Plan Changes

Upon completion, the student will be able to identify major changes in the Safety Data

Sheet (formally Material Safety Data Sheet) format, identify Safety and Health Labeling

requirements. Describe the new GHS Pictograms and Signal Words that identify the

hazards associated with a given chemical, understand the basics of the new system for

Hazard Classification. Be able to recognize employer requirements to prepare for and

implement the new requirements according to the allotted timeframe. Understand the

conflict between GHS and NFPA 704.

The emergency responder will be able to identify the new GHS Pictograms and Signal

Words, identifying them in a timely manner from a given chart.

The emergency responder will describe the basics of the new system for Hazard

Classification and the differences of the NFPA 704 system by completing a written list of

differences.

The emergency responder will list and identify the major changes in the Safety Data

Sheet, through completion of assigned activities.

Page 7: Instructor Guide Globally Harmonized System for Hazard ...Globally Harmonized System For Hazard Communication MU221-15 GHS Awareness Level Training 10/22/13 MU221-15 GHS Awareness

Globally Harmonized System For Hazard Communication

MU221-15 GHS Awareness Level Training

10/22/13 MU221-15 GHS Awareness Page 7 www.feti.lsu.edu

The emergency responder will identify the employer requirements for implementation

and the timeframe required.

The emergency responder will demonstrate understanding of the changes to National Fire

Protection (NFPA) 704, though practical application and the activity completion process.

Page 8: Instructor Guide Globally Harmonized System for Hazard ...Globally Harmonized System For Hazard Communication MU221-15 GHS Awareness Level Training 10/22/13 MU221-15 GHS Awareness

Globally Harmonized System For Hazard Communication

MU221-15 GHS Awareness Level Training

10/22/13 MU221-15 GHS Awareness Page 8 www.feti.lsu.edu

I. Lesson Plan Components

A. Preparation

1. Preparing to teach

a. Become familiar with the information to be taught.

b. Use material provided to meet performance objectives.

c. Ensure you have enough materials, activity worksheets, ERG’s.

d. Know your material discus the slides don’t read them to your students.

e. Know your audience, delivering this material to rookie firefighters might require a

different approach than to a veteran hazardous materials technician level response

team.

2. Prepare the students to learn

a. Motivation.

b. Relate lesson to past experience with examples or references, do not get off into

war stories unless relevant to specifics of this class

c. State and show objectives.

d. Overview/main points.

B. Presentation

1. Deliver instruction

a. Present/explain new information.

b. Demonstrate techniques.

c. Provide for skills practice.

d. Give assignments.

2. Promote discussion

a. Involve the class with discussion of their own response area and how it relates.

Page 9: Instructor Guide Globally Harmonized System for Hazard ...Globally Harmonized System For Hazard Communication MU221-15 GHS Awareness Level Training 10/22/13 MU221-15 GHS Awareness

Globally Harmonized System For Hazard Communication

MU221-15 GHS Awareness Level Training

10/22/13 MU221-15 GHS Awareness Page 9 www.feti.lsu.edu

b. Ask questions.

3. Deliver in logical sequence

a. Basic to complex steps.

4. Combine/vary teaching methods

a. Accommodate various learning styles.

5. Summarize/review main points

C. Presentation

Globally Harmonized System Awareness Training

1. Slide: 1

a. Number: 1

i. This training session is designed to provide information to public

response agencies concerning the changes in the MSDS system to the

SDS system.

ii. We will cover some of the basics concerning employees who work with

hazardous chemicals and substances.

iii. The dates we need to know concerning the changes and implementation

schedule.

iv. How it will affect us in response, and what we need to do for our own in

station HazCom Plan.

v. Employers are required to provide training to employees by December 1, 2013.

2. Slide: 2

a. Course Paperwork at the start of the class

Page 10: Instructor Guide Globally Harmonized System for Hazard ...Globally Harmonized System For Hazard Communication MU221-15 GHS Awareness Level Training 10/22/13 MU221-15 GHS Awareness

Globally Harmonized System For Hazard Communication

MU221-15 GHS Awareness Level Training

10/22/13 MU221-15 GHS Awareness Page 10 www.feti.lsu.edu

3. Slide: 3

a. Course objectives.

4. Slide: 4

a. Course objectives continues.

b. Read slide for students to emphasis

5. Slide: 5

a. The Why – The Who – The How

i. Why the Changes to HazCom.

ii. Who does it affect?

iii. How it works.

iv. What other standards are affected.

v. Timeline for the changes.

6. Slide: 6

a. So, why the change?

i. Since 1992, the United Nations has been working to create and enhance

a globally harmonized system for the classification and labeling of

chemicals that can be used by importers, distributors, and manufacturers

worldwide.

ii. This has been an ongoing process and the new 2012 HazCom standard is

based on the GHS revision 3 standard.

iii. The goal is to provide a common and coherent approach to classifying

chemicals.

iv. How this will benefit employees and you as responders will be:

1. Reduce confusion and increase understanding of the hazards.

Page 11: Instructor Guide Globally Harmonized System for Hazard ...Globally Harmonized System For Hazard Communication MU221-15 GHS Awareness Level Training 10/22/13 MU221-15 GHS Awareness

Globally Harmonized System For Hazard Communication

MU221-15 GHS Awareness Level Training

10/22/13 MU221-15 GHS Awareness Page 11 www.feti.lsu.edu

2. Have only one type of SDS – as opposed to the current different

formats for MSDS.

3. Help address literacy problems particularly due to use of

pictograms.

7. Slide: 7

a. Manufacturers – Distributors – and Importers will face the biggest challenge

due to a couple of factors:

i. The change to SDS format and information.

ii. The changes to container labeling and the requirements.

b. Training Officers – both corporate and company officers within response

agencies will have a responsibility to ensure that all employees are trained to the

new standard effective December 1, 2013.

i. This will include the new 16 section SDS format and the new labeling

system which includes secondary containers.

c. Employees will be affected in the fact they will need to recognize and

understand hazards based on:

i. Information in the new 16 section SDS format.

ii. Pictograms on container labels and the format changes.

iii. Precautionary and hazard statements.

8. Slide: 8

a. The graph illustrates how the HazCom system is supposed to work.

i. Talk through the graph to the class showing the relationships.

9. Slide: 9

a. The language on some signs will also change.

b. Other U.S. Agencies that are affected:

i. The Department of Transportation (DOT)

Page 12: Instructor Guide Globally Harmonized System for Hazard ...Globally Harmonized System For Hazard Communication MU221-15 GHS Awareness Level Training 10/22/13 MU221-15 GHS Awareness

Globally Harmonized System For Hazard Communication

MU221-15 GHS Awareness Level Training

10/22/13 MU221-15 GHS Awareness Page 12 www.feti.lsu.edu

1. DOT has already modified its requirements for classification and

labeling to make them consistent with United Nations transport

requirements and the new globally harmonized system.

ii. Environmental Protection Agency (EPA)

iii. Consumer Product Safety Commission (CPSC)

1. Actively participated in developing the GHS.

c. Other standards affected:

i. 1910.120 (HAZWOP-ER) and 1910.119 (Process Safety Management)

Standard.

1. Incorporates the current HCS definitions of flammable liquid and

gas.

ii. 1910.252 (Welding) standard.

1. Requirements on labeling, welding, consumables to be consistent

with GHS modifications to HCS.

2. Amend paragraphs on flammable and combustible liquids to

conform categories, terminology, flashpoints (FP), and boiling

points to the GHS modifications to HCS.

iii. 1910.106 (Flammable/Combustible Liquids) Standard.

1. Incorporate the modified HCS definition of flammable aerosols

into the Flammable and Combustible Liquids standard.

2. Update the acceptable methods for determining flashpoints.

10. Slide: 10

a. This chart was provided by Federal OSHA.

i. Effective on or by June 1, 2015:

1. All SDS must be completed and shipped/sent to users with the 1st

order shipped on or after June 1, 2015.

Page 13: Instructor Guide Globally Harmonized System for Hazard ...Globally Harmonized System For Hazard Communication MU221-15 GHS Awareness Level Training 10/22/13 MU221-15 GHS Awareness

Globally Harmonized System For Hazard Communication

MU221-15 GHS Awareness Level Training

10/22/13 MU221-15 GHS Awareness Page 13 www.feti.lsu.edu

2. Employers/users of chemicals review to ensure all SDS received

on or after June 1, 2015 are in the new format.

ii. Per OSHA, employers are not required to pursue getting new SDSs for

products received before June 1, 2015.

1. Unless they are aware of changes to the hazards in the product.

2. Older products, material safety data sheets for the products must

kept as long as the chemical is onsite/used - then archived as

required.

11. Slide: 11 –continuation of above

i. Vertical chemical specific standards with label requirements.

1. Must be changed to harmonize with 1910.1200 HazCom.

2. Effective on or by June 1, 2016

a. Employer/user must have program updated.

b. Include any additional training.

c. Ensure label changes are completed.

ii. Vertical chemical specific standards with signage requirements will be

changing to harmonize with 1910.1200 HazCom.

12. Slide – title - Classifications

13. Slide 13

a. We will discuss the three chemical classifications.

b. The comparison of changes between the 1994 and 2012 HazCom standard.

c. The new definitions and the terms or words that have been removed from the

older standard.

14. Slide: 14

a. Previously, chemical hazards were evaluated in a more subjective manner.

Page 14: Instructor Guide Globally Harmonized System for Hazard ...Globally Harmonized System For Hazard Communication MU221-15 GHS Awareness Level Training 10/22/13 MU221-15 GHS Awareness

Globally Harmonized System For Hazard Communication

MU221-15 GHS Awareness Level Training

10/22/13 MU221-15 GHS Awareness Page 14 www.feti.lsu.edu

b. Now we will be using a “specification” approach rather than a “performance-

oriented” approach and it will be:

i. “Hazard classification” rather than “hazard determination”

c. Chemicals must now go through a specific, prescriptive classification process.

i. This will determine which hazards are present.

ii. Which hazard and precautionary statements apply.

iii. This can be a lengthy process.

iv. Appendix A can tell you more about the classification process.

15. Slide: 15

a. The comparisons and changes from the 1994 HazCom Standard to the 2012

HazCom Standard.

i. Discuss the changes and comparisons.

16. Slide: 16

a. Definitions for both Standards:

i. HazCom 1994

ii. HazCom 2012

b. Talk about slide – the comparisons – and or the changes.

c. Note that:

i. “Some definitions are revised to be GHS-consistent”.

ii. New definitions have been added for classification.

17. Slide: 17 - title - Labels Overview

a. Hazard Classification

i. Note the changes.

ii. Discuss the comparisons.

b. Section contains the new information concerning the changes to labels

18. Slide: 18

Page 15: Instructor Guide Globally Harmonized System for Hazard ...Globally Harmonized System For Hazard Communication MU221-15 GHS Awareness Level Training 10/22/13 MU221-15 GHS Awareness

Globally Harmonized System For Hazard Communication

MU221-15 GHS Awareness Level Training

10/22/13 MU221-15 GHS Awareness Page 15 www.feti.lsu.edu

a. Labels and other information that has now changed along with a comparison

of both the old and new standard

i. Information comparison of HazCom 1994.

ii. Information comparison of HazCom 2012.

19. Slide: 19

a. Container labels and the requirements to meet the 2012 HazCom standard

i. This is a provided example of the new label style.

1. Beginning no later than June 1, 2015.

a. A provided exception will be Dec. 1, 2015 for

distributers who still have product in inventory after the

June 1, 2015 deadline.

ii. The type of required information is noted in blue on the label.

1. Keep in mind the actual statements and information will vary

depending on the specific health and physical classification of

the product.

20. Slide: 20

a. Note there is a difference in how the shipping labels and the containers look

i. The purpose of this is for quick and easy identification.

b. Department of Transportation (DOT) requires that additional information be

noted on shipping containers.

i. See bottom right corner of the label for shipping.

21. Slide: 21 (content on two slides for viewing)

a. Side by side view of each type of label

b. Discuss the differences and what information we need or want in emergency

response.

c. One on the right is a container label – one on the left is shipping label.

Page 16: Instructor Guide Globally Harmonized System for Hazard ...Globally Harmonized System For Hazard Communication MU221-15 GHS Awareness Level Training 10/22/13 MU221-15 GHS Awareness

Globally Harmonized System For Hazard Communication

MU221-15 GHS Awareness Level Training

10/22/13 MU221-15 GHS Awareness Page 16 www.feti.lsu.edu

22. Slide 22

a. The Department of Transportation (DOT) and shipping labels

i. DOT does not view the GHS pictograms as a conflict.

ii. It is permissible to have the DOT and GHS pictogram for representing

the same hazard.

b. OSHA will not be enforcing the “shall not appear” requirement in Appendix C

i. Appendix C - (C.2.3.3. states “where a pictogram is required by DOT

under Title 49 of the Code of Federal Regulations (CFR) appears on a

shipped container, the pictogram specified in C.4 for the same hazard,

shall not appear.”

23. Slide: 23 and 24

a. Department of Transportation (DOT) placards and signage

i. This chart illustrates the placard system of markings.

1. Very little if any real noticeable changes have taken place.

ii. Signage however, as we previously discussed will have some changes.

1. Remember the sign concerning “Lead” we looked at earlier.

24. Slide: 25

a. Pictograms this is a new element of the 2012 HazCom Standard

b. “Pictogram” means a composition that may include a symbol plus other graphic

elements

i. Examples include such items as:

1. Borders.

2. Background patterns.

3. Color that is intended to convey specific information about the

hazards of a chemical.

c. There are 3 pictograms specific to health hazards:

Page 17: Instructor Guide Globally Harmonized System for Hazard ...Globally Harmonized System For Hazard Communication MU221-15 GHS Awareness Level Training 10/22/13 MU221-15 GHS Awareness

Globally Harmonized System For Hazard Communication

MU221-15 GHS Awareness Level Training

10/22/13 MU221-15 GHS Awareness Page 17 www.feti.lsu.edu

i. Exclamation.

ii. Health hazard (silhouette of a person with starburst on the chest).

iii. Skull and crossbones.

d. There is one pictogram that can represent both a physical and/or health hazard

of corrosive.

e. There are four pictograms specific to physical hazards:

i. Exploding bomb.

ii. Flame.

iii. Flame over circle (oxidizer)

iv. Gas cylinder.

f. There is one for environment:

i. Oxidizers are chemicals that can emit oxygen and increase the risk of

fire.

25. Slide: 26

a. Boarders and the boarder colors

i. Boarder colors are Red

ii. Borders can also be the color back.

b. Red stands out more

i. Remember no blank red diamonds.

c. OSHA proposed to require labels to be updated

i. The period was to be within three months of getting new and significant

information about the hazards.

d. The final rule requires containers shipped six months after the information is

available to be labeled accordingly.

26. Slide: 27

Page 18: Instructor Guide Globally Harmonized System for Hazard ...Globally Harmonized System For Hazard Communication MU221-15 GHS Awareness Level Training 10/22/13 MU221-15 GHS Awareness

Globally Harmonized System For Hazard Communication

MU221-15 GHS Awareness Level Training

10/22/13 MU221-15 GHS Awareness Page 18 www.feti.lsu.edu

a. Signal words – this is another change and one that will help us as first

responders for quick identification

b. In the past, there have been several signal words that may have been used to

indicate a hazard.

i. Words such as:

1. Caution.

2. Warning.

3. Danger.

c. The GHS permits only the use of two signal words:

i. Danger

ii. Warning.

d. Only one of the signal words is permitted to appear on the label based on the

classification of the chemical.

27. Slide: 28 Hazard Statement appears on the label

i. Definition of Hazard Statement:

1. "Hazard statement" means a statement assigned to a hazard class

and category that describes the nature of the hazard(s) of a

chemical, including, where appropriate, the degree of hazard.

ii. Manufacturers, importers, and distributers use the classification system

outlined in GHS.

1. The purpose is to identify which statements must appear in the

SDS and on the label found in Appendix C.

a. Example: Fatal if swallowed (Acute Oral Toxicity).

28. Slide: 29

a. Precautionary Statements

i. Recommended measures related to:

Page 19: Instructor Guide Globally Harmonized System for Hazard ...Globally Harmonized System For Hazard Communication MU221-15 GHS Awareness Level Training 10/22/13 MU221-15 GHS Awareness

Globally Harmonized System For Hazard Communication

MU221-15 GHS Awareness Level Training

10/22/13 MU221-15 GHS Awareness Page 19 www.feti.lsu.edu

1. Prevention.

2. Response.

3. Storage.

4. Disposal.

a. Examples include things such as:

1. Wear respiratory protection.

2. Wash with soap and water.

3. Store in a well ventilated place.

29. Slide: 30

a. Product Identification in the 2012 HazCom Standard

i. Definition of product identifier:

1. "Product identifier" means the name or number used for a

hazardous chemical on a label or in the SDS.

a. It provides a unique means by which the user can

identify the chemical.

b. The product identifier used shall permit cross-references

to be made among the list of hazardous chemicals

required in the written hazard communication program,

the label and the SDS.

30. Slide: 31

a. This chart has all of the information we would need to know concerning labels

i. Talk over the chart.

31. Slide: 32

a. The OSHA quick card:

i. You can find the cards with the ready to go information concerning

labels.

Page 20: Instructor Guide Globally Harmonized System for Hazard ...Globally Harmonized System For Hazard Communication MU221-15 GHS Awareness Level Training 10/22/13 MU221-15 GHS Awareness

Globally Harmonized System For Hazard Communication

MU221-15 GHS Awareness Level Training

10/22/13 MU221-15 GHS Awareness Page 20 www.feti.lsu.edu

ii. The cards are located at the OSHA website.

iii. The cards can be printed out as wallet cards.

32. Slide: 31

a. Secondary containment and the GHS vs. HazCom 2012 debate

33. Slide: 32

a. Excerpt from the Hazard Communication Standard (f):

i. (6) Workplace labeling. Except as provided in paragraphs (7) and (8) of

this section.

1. The employer shall ensure that each container of hazardous

chemicals in the workplace is labeled, tagged or marked with

either:

a. (i) The information specified under paragraphs (1).

b. (i) Through (v) of this section for labels on shipped

containers.

ii. GHS Label or:

iii. (ii) Product identifier and:

1. Words.

2. Pictures.

3. Symbols.

4. Or combination thereof.

a. Which provides at least general information regarding

the hazards of the chemicals, and which, in conjunction

with the other information immediately available to

employees under the hazard communication program,

will provide employees with the specific information

Page 21: Instructor Guide Globally Harmonized System for Hazard ...Globally Harmonized System For Hazard Communication MU221-15 GHS Awareness Level Training 10/22/13 MU221-15 GHS Awareness

Globally Harmonized System For Hazard Communication

MU221-15 GHS Awareness Level Training

10/22/13 MU221-15 GHS Awareness Page 21 www.feti.lsu.edu

regarding the physical and health hazards of the

hazardous chemical.

1. Examples being.

1. Hazardous Materials Information System

(HMIS).

2. National Fire Protection Association

(NFPA).

3. Or other label system.

34. Slide: 33 – title slide

35. Slide 34 Secondary containment defined

36. Slide 35

a. Play the video – mention the importance and differences in the NFPA 704 and

the HazCom 2012 rating scale

i. The National Fire Protection Associations NFPA 704 will still be a

viable system.

ii. The HazCom 2012 rating will also be used.

37. Slide: 36

a. The labeling of secondary containment and marking requirements

b. This is covered by:

i. Hazardous Materials Information System (HMIS).

1. The HMIS labeling system incorporates an “*” to inform

employees of the presence of a chronic/target organ health effect.

ii. National Fire Protection Association (NFPA).

1. This labeling system does not incorporate chronic effects.

a. However, this must be included on the NFPA labeled

secondary containers.

Page 22: Instructor Guide Globally Harmonized System for Hazard ...Globally Harmonized System For Hazard Communication MU221-15 GHS Awareness Level Training 10/22/13 MU221-15 GHS Awareness

Globally Harmonized System For Hazard Communication

MU221-15 GHS Awareness Level Training

10/22/13 MU221-15 GHS Awareness Page 22 www.feti.lsu.edu

1. Provided the product was noted on the original

manufacturer container.

1. The health hazard pictogram this would

apply to is the (silhouette of a person with

starburst on chest).

c. GHS vs. HMIS / NFPA 704

i. NFPA & HMIS systems number “4” indicates a severe hazard.

ii. Under the GHS HazCom standard, when a manufacturer, importer,

distributer classifies a chemical, a category “4” is the least severe and a

category “1” is the most severe.

d. GHS hazard category numbers may be noted in SDS;

i. This is NOT required to be present on the container label.

e. ACA made modifications to HMIS ratings in 2001

i. Reactivity was changed to a Physical Hazard and the defined ranges

were modified.

1. System is still:

a. 0 = least hazard.

b. 4 = greatest hazard.

1. More information available at

www.paint.org/programs/hmis.html

38. Slide: 37 and 38

a. This chart is provided to show a comparison between NFPA 704 and HazCom

2012

i. Discus the chart

1. Point out the most import part, which is the rating scale.

a. NFPA 704.

Page 23: Instructor Guide Globally Harmonized System for Hazard ...Globally Harmonized System For Hazard Communication MU221-15 GHS Awareness Level Training 10/22/13 MU221-15 GHS Awareness

Globally Harmonized System For Hazard Communication

MU221-15 GHS Awareness Level Training

10/22/13 MU221-15 GHS Awareness Page 23 www.feti.lsu.edu

1. 0 = Least Hazardous.

2. 4 = Most Hazardous.

b. HazCom 2012.

1. 1 = Most sever.

2. 4 = Least sever.

1. The required numbers are not required on

labels.

2. The numbers are required on the SDS.

a. In Section Two.

39. Slide: 39 – title slide – SDS

a. Safety Data Sheets formerly known as Material Safety Data Sheets

i. SDS went under a large format change.

1. This however is a change for the better as now all SDS will be

the same.

2. Information will be in the same format regardless of product or

country of origin.

40. Slide: 40

a. This is a brief that was produced by the Occupational Health and Safety

Administration (OSHA)

b. What this is telling us is that manufacturers, importers and distributers may

begin using the new 16-section format SDS (follows the ANSI standard) during

the transition from the 1994 HazCom standard and the final 2012 HazCom

standard but no later than June 1, 2015.

i. They are required to provide a revised copy of the MSDS/SDS to the

employer anytime changes are made to the product.

Page 24: Instructor Guide Globally Harmonized System for Hazard ...Globally Harmonized System For Hazard Communication MU221-15 GHS Awareness Level Training 10/22/13 MU221-15 GHS Awareness

Globally Harmonized System For Hazard Communication

MU221-15 GHS Awareness Level Training

10/22/13 MU221-15 GHS Awareness Page 24 www.feti.lsu.edu

c. Employers are required to maintain copies of all SDSs for the chemicals used

and/or stored within the work area.

i. They should have a system to ensure all SDSs are present/accounted for.

ii. Periodically check for the most current SDS (usually based on revision

date) when received from a manufacturer, importer or distributer.

d. The most current SDS needs to be displayed or placed into the accessible

HazCom location.

i. Old or replaced MSDS should be archived prior to the new SDSs.

ii. SDSs are to be accessible/available to employees.

iii. Regular updates are required.

e. As stated previously, if a manufacturer is no longer in business, material

safety data sheets for the product must kept as long as chemical is onsite/used

then archived as required.

41. Slide: 41

a. Section one of the SDS is Identification

i. Appendix D provides additional requirements for the information to be

included under each section heading.

ii. Section 1 requires restriction(s) on use.

42. Slide: 42

a. Section two of the SDS is Hazard(s) Identification

i. Section 2 requires:

1. Classification a Signal word.

2. Symbols.

3. Hazard and precautionary statements.

4. Hazards not otherwise classified.

Page 25: Instructor Guide Globally Harmonized System for Hazard ...Globally Harmonized System For Hazard Communication MU221-15 GHS Awareness Level Training 10/22/13 MU221-15 GHS Awareness

Globally Harmonized System For Hazard Communication

MU221-15 GHS Awareness Level Training

10/22/13 MU221-15 GHS Awareness Page 25 www.feti.lsu.edu

5. Unknown toxicity statements when 1% or more of the

components has unknown toxicity.

a. “X percent of the mixture consists of ingredients of

unknown toxicity.”

43. Slide: 43

a. Section three requires Composition / Information on Ingredients

i. Section 3 requires:

1. Ingredient information.

2. Substances.

3. Mixtures

4. Use of concentration ranges if the product is listed as a trade

secret.

44. Slide: 44

a. Section four is First Aid

i. Section 4 requires:

1. To be designed for the untrained responder to provide care until

medical care arrives.

b. Section five is Fire Fighting Measures

i. Section 5 requires:

1. Recommendations of suitable extinguishing equipment.

2. Information about extinguishing equipment that is not

appropriate for a particular situation.

3. Advice on specific hazards that develop from the chemical

during the fire.

a. Any hazardous combustion products created when the

chemical burns.

Page 26: Instructor Guide Globally Harmonized System for Hazard ...Globally Harmonized System For Hazard Communication MU221-15 GHS Awareness Level Training 10/22/13 MU221-15 GHS Awareness

Globally Harmonized System For Hazard Communication

MU221-15 GHS Awareness Level Training

10/22/13 MU221-15 GHS Awareness Page 26 www.feti.lsu.edu

ii. Recommendations on special protective equipment or precautions for

firefighters.

45. Slide: 45

a. Section six is Accidental Release Measures

i. Section 6 requires:

1. Use of personal precautions.

2. Such as removal of ignition sources.

3. Providing sufficient ventilation.

4. Protective equipment.

a. To prevent the contamination of:

1. Skin.

2. Eyes.

3. Clothing.

5. Emergency procedures, including instructions for

a. Evacuations.

b. Consulting experts when needed.

c. Appropriate protective clothing.

6. Methods and materials used for containment.

7. Covering the drains and capping procedures.

8. Cleanup procedures.

a. Appropriate techniques for Neutralization.

1. Contamination.

2. Cleaning.

3. Vacuuming.

4. Adsorbent materials.

5. Equipment required for containment/clean up.

Page 27: Instructor Guide Globally Harmonized System for Hazard ...Globally Harmonized System For Hazard Communication MU221-15 GHS Awareness Level Training 10/22/13 MU221-15 GHS Awareness

Globally Harmonized System For Hazard Communication

MU221-15 GHS Awareness Level Training

10/22/13 MU221-15 GHS Awareness Page 27 www.feti.lsu.edu

46. Slide: 46

a. Section seven Handling and Storage

i. The required information in section seven consists of:

1. Precautions for safe handling.

a. Including recommendations for handling incompatible

chemicals.

2. Minimizing the release of the chemical into the environment.

3. Providing advice on general hygiene practices such as:

a. Eating.

b. Drinking.

c. Smoking in work areas is also prohibited.

ii. Recommendations on the conditions for safe storage.

1. Including any incompatibilities.

2. Providing advice on specific storage requirements.

b. Section eight consists of Exposure Controls and Personal Protection

i. The required information consists of:

1. OSHA Permissible Exposure Limits (PELs).

2. American Conference of Governmental Industrial Hygienists

(ACGIH) threshold Limit Values (TLVs).

3. Any other exposure limit used or recommended by the:

a. Chemical manufacturer.

b. Importer.

c. Employer preparing the safety data sheet.

ii. Appropriate engineering controls such as:

1. Local exhaust ventilation.

Page 28: Instructor Guide Globally Harmonized System for Hazard ...Globally Harmonized System For Hazard Communication MU221-15 GHS Awareness Level Training 10/22/13 MU221-15 GHS Awareness

Globally Harmonized System For Hazard Communication

MU221-15 GHS Awareness Level Training

10/22/13 MU221-15 GHS Awareness Page 28 www.feti.lsu.edu

iii. Recommendations for personal protective measures to prevent illness or

injury from exposure to chemicals, such as personal protective

equipment (PPE).

1. Appropriate types of:

a. Eye.

b. Face.

c. Skin.

d. Respiratory protection needed based on hazards.

e. Potential exposure.

iv. Any special requirements for PPE, protective clothing or respirators

(e.g., type of glove material, such as PVC or nitrile rubber gloves; and

breakthrough time of the glove material).

47. Slide: 47

a. Section nine includes Physical and Chemical Properties

i. The SDS may not contain every item on the above list because

information may not be relevant or is not available.

ii. When this occurs, a notation to that effect must be made for that

chemical property.

iii. Manufacturers may also add other relevant properties.

1. Such as the dust deflagration index (Kst) for combustible dust,

used to evaluate a dust’s explosive potential.

48. Slide: 48

a. Section ten consists of Stability and Reactivity

i. The required information consists of:

ii. Reactivity

1. Description of the specific test data for the chemical(s).

Page 29: Instructor Guide Globally Harmonized System for Hazard ...Globally Harmonized System For Hazard Communication MU221-15 GHS Awareness Level Training 10/22/13 MU221-15 GHS Awareness

Globally Harmonized System For Hazard Communication

MU221-15 GHS Awareness Level Training

10/22/13 MU221-15 GHS Awareness Page 29 www.feti.lsu.edu

a. This data can be for a class or family of the chemical if

such data adequately represents the anticipated hazard of

the chemical(s).

iii. Chemical stability

1. Indication of whether the chemical is stable or unstable under

normal ambient temperature and conditions while in storage and

being handled.

2. Description of any stabilizers that may be needed to maintain

chemical stability.

3. Indication of any safety issues that may arise should the product

change in physical appearance.

iv. Other

1. Indication of the possibility of hazardous reactions, including a

statement whether the chemical will react or polymerize, which

could release excess pressure or heat, or create other hazardous

conditions.

2. Also, a description of the conditions under which hazardous

reactions may occur.

3. List of all conditions that should be avoided such as:

a. Static discharge.

b. Shock.

c. Vibrations.

d. Environmental conditions that may lead to hazardous

conditions.

4. List of all classes of incompatible materials such as:

a. Classes of chemicals or specific substances.

Page 30: Instructor Guide Globally Harmonized System for Hazard ...Globally Harmonized System For Hazard Communication MU221-15 GHS Awareness Level Training 10/22/13 MU221-15 GHS Awareness

Globally Harmonized System For Hazard Communication

MU221-15 GHS Awareness Level Training

10/22/13 MU221-15 GHS Awareness Page 30 www.feti.lsu.edu

1. Which the chemical could react to produce a

hazardous situation.

5. List of any known or anticipated hazardous decomposition

products that could be produced because of:

a. Use.

b. Storage.

c. Heating.

1. Hazardous combustion products should also be

included in Section 5 (Fire-Fighting Measures)

of the SDS.

49. Slide: 49

a. Section eleven consists of Toxicology Information

i. The required information consists of:

1. Information on the likely routes of exposure such as:

a. Inhalation.

b. Ingestion.

c. Skin contact.

d. Eye contact.

ii. The SDS should indicate if the information is unknown.

iii. Description of the delayed, immediate, or chronic effects from short-

and long-term exposure.

iv. The numerical measures of toxicity (e.g., acute toxicity estimates such as

the LD50 (median lethal dose)) - the estimated amount [of a substance]

expected to kill 50% of test animals in a single dose.

v. Description of the symptoms.

Page 31: Instructor Guide Globally Harmonized System for Hazard ...Globally Harmonized System For Hazard Communication MU221-15 GHS Awareness Level Training 10/22/13 MU221-15 GHS Awareness

Globally Harmonized System For Hazard Communication

MU221-15 GHS Awareness Level Training

10/22/13 MU221-15 GHS Awareness Page 31 www.feti.lsu.edu

1. This description includes the symptoms associated with exposure

to the chemical including symptoms from the lowest to the most

severe exposure.

vi. Indication of whether the chemical is listed in the National Toxicology

Program (NTP) Report on Carcinogens (latest edition) or has been found

to be a potential carcinogen in the International Agency for Research on

Cancer (IARC) Monographs (latest editions) or found to be a potential

carcinogen by OSHA.

50. Slide: 50

a. Section twelve consists of Ecological Information (non-mandatory)

i. Non-mandatory is the key to this whole area, the majority of the time

responsible manufacturers will complete this section.

ii. To be GHS-compliant, the requirements for this section would be:

1. Eco-toxicity both:

a. Aquatic

b. Terrestrial where available.

2. Persistence.

3. Degradability.

4. Bioaccumulative potential.

5. Mobility in soil.

6. Any other adverse effects.

51. Slide 51

a. Section thirteen consists of Disposal Considerations (non-mandatory)

i. To be GHS compliant, this section is provided, but compliance is outside

OSHA jurisdiction.

Page 32: Instructor Guide Globally Harmonized System for Hazard ...Globally Harmonized System For Hazard Communication MU221-15 GHS Awareness Level Training 10/22/13 MU221-15 GHS Awareness

Globally Harmonized System For Hazard Communication

MU221-15 GHS Awareness Level Training

10/22/13 MU221-15 GHS Awareness Page 32 www.feti.lsu.edu

1. However, OSHA may enforce provisions associated with safe

handling and use, including appropriate hygienic practices.

ii. Description of waste residues.

iii. Information on their safe handling.

iv. Methods of disposal.

v. Disposal of any contaminated packaging.

vi. Again, keep in mind this is a non-mandatory section.

52. Slide: 52

a. Section fourteen consists of Transport Information (non-mandatory)

i. To be GHS compliant, this section is provided, but compliance is outside

OSHA jurisdiction.

1. The required transport information however should include:

a. UN number.

b. UN proper shipping name.

c. Transport hazard classes.

d. Packing group, if applicable

2. Environmental hazards such as marine pollutant (yes/no)

3. Transport in bulk (per Annex II of MARPOL 73/78 and IBC

Code).

4. Special precautions which a user needs to be aware of or needs to

comply with, in connection with transport or conveyance either

within or outside their premises.

53. Slide: 53

a. Section fifteen consists of Regulatory Information (non-mandatory)

i. To be GHS compliant, this section is provided, but compliance is outside

OSHA jurisdiction.

Page 33: Instructor Guide Globally Harmonized System for Hazard ...Globally Harmonized System For Hazard Communication MU221-15 GHS Awareness Level Training 10/22/13 MU221-15 GHS Awareness

Globally Harmonized System For Hazard Communication

MU221-15 GHS Awareness Level Training

10/22/13 MU221-15 GHS Awareness Page 33 www.feti.lsu.edu

1. Things that might be included in this section consist of:

a. Safety.

b. Health.

c. Environmental regulations specific to product.

b. Section sixteen consists of Other Information

i. New requirements to the SDS include this section which is used for:

1. Date of preparation of SDS.

2. The last revision date of the SDS.

3. Any additional information desired to be included that has no

specific location in the other sections.

54. Slide: 54

a. Employer Responsibilities

i. Discussion of the employer’s responsibilities in a wrap up of the

presentation.

55. Slide: 55

a. Summary

i. The student should now have better insight into the program changes.

ii. Methods to research material hazards.

iii. An understanding for a safer workplace.

iv. The changes to 2012 HazCom which includes:

1. MSDS to SDS.

2. Completing, reading and understanding the SDS.

3. Labeling requirements.

4. Secondary Containment.

5. The differences between HazCom 2012 and NFPA 704.

56. Slide: 56

Page 34: Instructor Guide Globally Harmonized System for Hazard ...Globally Harmonized System For Hazard Communication MU221-15 GHS Awareness Level Training 10/22/13 MU221-15 GHS Awareness

Globally Harmonized System For Hazard Communication

MU221-15 GHS Awareness Level Training

10/22/13 MU221-15 GHS Awareness Page 34 www.feti.lsu.edu

a. References

i. Occupational Safety and Health (OSHA) 29 CFR 1910.1200(g) and

Appendix D.

ii. United Nations Globally Harmonized System of Classification and

Labeling of Chemicals (GHS), third revision edition, United Nations,

2009.

iii. National Fire Protection Association (NFPA) 704.

iv. Department of Transportation (DOT).

v. Environmental Protection Agency (EPA).

Page 35: Instructor Guide Globally Harmonized System for Hazard ...Globally Harmonized System For Hazard Communication MU221-15 GHS Awareness Level Training 10/22/13 MU221-15 GHS Awareness

Globally Harmonized System For Hazard Communication

MU221-15 GHS Awareness Level Training

10/22/13 MU221-15 GHS Awareness Page 35 www.feti.lsu.edu

Summary:

Review:

Remotivation:

Assignment:

EVALUATION: